G.R. No. 141519; January 22, 2004
PEOPLE OF THE PHILIPPINES, Appellee, vs. SONNY CANON alias “POGI,” Appellant.

FACTS

The appellant, Sonny Canon, was charged with the rape of Maryjane C. Borsong, a 16-year-old minor described as a mental retardate. The prosecution alleged that in December 1997, in Barangay San Vicente, Buhi, Camarines Sur, appellant, armed with a fan knife, used force and intimidation to have carnal knowledge of Maryjane while she was home alone. The victim’s pregnancy, discovered in February 1998, led to the revelation of the rape. Medical examination confirmed her pregnancy and her inferior mental capacity. The Regional Trial Court convicted appellant of rape and sentenced him to reclusion perpetua.
Appellant denied the charge, claiming he and Maryjane were sweethearts and that their sexual encounters were consensual. He asserted that the complaint was filed after Maryjane’s parents rejected his marriage proposal. Defense witness Marcelino Apante corroborated the sweetheart theory, testifying he once saw the two engaged in sexual intercourse. On rebuttal, Maryjane denied any romantic relationship with appellant.

ISSUE

Whether the prosecution proved the guilt of the appellant for the crime of rape beyond reasonable doubt.

RULING

Yes. The Supreme Court affirmed the conviction. The Court found Maryjane’s testimony credible, straightforward, and consistent. As a mental retardate, her narration of the incident—wherein appellant poked a knife at her neck, covered her mouth, and proceeded with the sexual act—was deemed sufficient to establish the elements of rape through force and intimidation. The Court emphasized that the credibility of a rape victim, especially one with mental deficiency, is not diminished by the simplicity of her testimony.
The appellant’s sweetheart defense was rejected for lack of credible corroboration. The Court found Apante’s testimony incredible, as it defied belief that a minor would allow a witness to observe a sexual act without shame. Moreover, Apante’s claim that Maryjane spoke normally contradicted the established evidence of her speech impediment. The Court held that even if a sweetheart relationship existed, it does not preclude the commission of rape. The crime was qualified by the use of a deadly weapon (fan knife), warranting the penalty of reclusion perpetua to death. With no aggravating or mitigating circumstances, the lesser penalty of reclusion perpetua was correctly imposed. The Court modified the damages, awarding an additional P50,000.00 as moral damages.